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NAMM Issues Public Comment in Response to Revised Lacey Act Provisions

Christian Wissmuller • Upfront • May 20, 2020

On May 20, NAMM issued a public comment in response to Animal and Plant Health Inspection Service’s (APHIS) proposed implementation of Phase VI of the Lacey Act enforcement schedule. This new schedule adds several product categories to the declaration required whenever certain covered plant products are brought into the country (read the federal register notice). At this time, an import declaration is required only for pianos and other stringed instruments (HTS Codes 9201 and 9202) and with the expansion, will include a broad range of other music instruments, accessories and parts.

In the letter, NAMM requested that the effective date for the declaration filing be set six months after the final notice is issued to allow NAMM member companies sufficient time to gather the required information and if needed, adjust internal process, and that the restated enforcement policy surrounding the term “import” be included in the Phase VI declaration.

NAMM will continue to work on this issue with APHIS and in partnership with other industry groups.

To read the full letter and for the latest updates on the Lacey Act and related advocacy, please visit:
https://www.namm.org/issues-and-advocacy/regulatory-compliance/endangered-species

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